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Anti-Corruption & Foreign Corrupt Practices Act (FCPA)

  • NYS Department of Financial Services Outlines Requirements for Transaction Monitoring and Filtering Programs of NY State-Licensed Institutions

    20 Jul 2016
    On June 30, 2016, the New York State Department of Financial Services (“NYSDFS”) adopted a final regulation outlining the attributes of a risk-based transaction monitoring and filtering program that certain New York State-licensed institutions now will be required to maintain (the “Final Rule”). The Final Rule includes several notable departures from the proposal that was issued by the NYSDFS on December 1, 2015 (the “Proposed Rule”). The Final Rule, which is the first significant rulemaking to be finalized under the direction of the new Superintendent of Financial Services, Maria T. Vullo, is another example of the NYSDFS asserting its role in establishing standards for compliance by banks with anti-money laundering, terrorist financing and sanctions laws.
  • Shearman & Sterling's Recent Trends and Patterns in the Enforcement of the Foreign Corrupt Practices Act (FCPA) / FCPA Digest

    5 Jul 2016

    Shearman & Sterling’s bi-annual Trends & Patterns report provides insightful analysis of recent enforcement trends and patterns in the US, the UK, and elsewhere as well as helpful guidance on emerging best practices in FCPA and global anti-corruption compliance programs.

  • To Self-Report or Not to Self-Report, That Remains the Question After the Justice Department’s Latest Effort to Encourage Self-Reporting

    29 Apr 2016

    On April 5, 2016, the United States Department of Justice, Criminal Division, Fraud Section launched a one-year Pilot Program that invites companies to self-report potential violations of the Foreign Corrupt Practices Act (“FCPA”) to the FCPA Unit of the Justice Department in exchange for, among other things, up to a fifty percent reduction in criminal fines, declination and, where appropriate, settlements without a compliance monitor.

  • Shearman & Sterling's Recent Trends and Patterns in the Enforcement of the Foreign Corrupt Practices Act (FCPA)/FCPA Digest

    4 Jan 2016
    Shearman & Sterling’s bi-annual Trends & Patterns report provides insightful analysis of recent enforcement trends and patterns in the US, the UK, and elsewhere as well as helpful guidance on emerging best practices in FCPA and global anti-corruption compliance programs.
  • Iran Sanctions Relief: Opportunities and Challenges for US and EU Financial Institutions

    28 Sep 2015

    Although US and EU sanctions targeting Iran are not likely to be lifted before early 2016, there are a number of issues which US and EU-based financial institutions should be aware of in preparation for sanctions relief as a result of recent international agreement to lift sanctions in the Joint Comprehensive Plan of Action (the "JCPOA"). This client note highlights some of the main issues.

  • Latin America Corruption: Keep Calm and Carry On?

    12 Aug 2015

    Recently, governmental authorities have pursued corruption investigations in Latin America with a vigor traditionally not seen. One potential result is a significant disruption of business. While there are inherent risks in executing business transactions with companies involved in these investigations, a number of precedents show that transactions can be done at acceptable levels of risk—if the proper steps are taken.

  • Urofsky, Torres-Fowler and Yeagley Publish Article on FCPA Challenges in International Sports

    15 Jul 2015
    Partner Philip Urofsky (Washington, DC-Litigation) and associates R. Zachary Torres-Fowler (New York-International Arbitration) and Jordan Yeagley (Washington, DC-Litigation) co-authored an article titled “Game Over,” published by Mining Journal on June 19.
  • Changes to Sanctions on Iran

    17 Jun 2015
    What are the prospects for business with Iran after the June 30 deadline to complete negotiations over Iran’s nuclear program? In exchange for limitations on Iran’s ability to develop nuclear weapons, the European Union (“EU”), the United Nations (“UN”), and the United States (“US”) would lift certain nuclear-related sanctions on Iran. Even with a positive outcome to the next round of discussions on the June 30 deadline, there are several key considerations.
  • FIFA and BHP Billiton: The Unique FCPA Challenges Present in International Sports

    15 Jun 2015

    Recent enforcement actions by the Department of Justice and Securities and Exchange Commission have raised the profile of corruption in international sports and highlight unique FCPA compliance concerns.

  • "Facilitation": A New Tool for Extraterritorial Sanctions Enforcement?

    17 Apr 2015
    Recent OFAC and DOJ actions have focused on certain entities—overseas financial institutions—and particular conduct—US dollar clearing and associated “stripping.” The DOJ’s recent $232 million settlement and negotiated criminal plea with Schlumberger Oilfield Holdings Ltd., however, reflects a break from this trend.
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